John A. Seavey - Page 7

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          raise any relevant issue with regard to the Commissioner's                  
          intended collection activities, including spousal defenses,                 
          challenges to the appropriateness of the Commissioner's intended            
          collection action, and alternative means of collection.  Secs.              
          6320(b), (c); 6330(c); see Sego v. Commissioner, 114 T.C. 604,              
          609 (2000); Goza v. Commissioner, 114 T.C. 176, 180 (2000).                 
               The taxpayer may raise challenges "to the existence or                 
          amount of the underlying tax liability", however, only if he "did           
          not receive any statutory notice of deficiency for such tax                 
          liability or did not otherwise have an opportunity to dispute               
          such tax liability."  Sec. 6330(c)(2)(B).                                   
               Pursuant to sections 6320(c) and 6330(c)(2)(B), petitioner             
          was entitled to challenge the existence or amount of the                    
          underlying tax liabilities for 1992, 1998, and 2000 at his                  
          Appeals Office hearing.  If the validity of those underlying tax            
          liabilities is properly at issue, the Court reviews the matter de           
          novo.  Poindexter v. Commissioner, 122 T.C. 280, 284 (2004); Sego           
          v. Commissioner, supra at 610.                                              
               Petitioner has failed to aver or prove facts sufficient to             
          show error in the assessments.  Indeed, petitioner testified that           
          he does not disagree with the amount of tax respondent determined           
          he owes.  He disputes the “fines and penalties” assessed on the             
          outstanding tax liabilities.                                                








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